Supplier Operating Principles
INTRODUCTION
Reed & Mackay is committed to good corporate governance is all areas. In simple terms, this means engaging in good business practices, while balancing the interests of a company’s many stakeholders, including directors/management, employees, clients, suppliers, investors / financiers, government/regulators, and the community. It is the company’s policy to be committed to integrity, ethical behaviours and professionalism and to comply with all laws and regulations that govern the conduct of its business.
In addition, as a signatory to the UN Global Compact (UNGC)1, Reed & Mackay has pledged to incorporate the ten principles of the UNGC2 into our strategy, operations and decision making. The Supplier Operating principles help to reinforce that commitment by setting out the expectations we have of suppliers. We recognise the value in working closely with our suppliers and appreciate the need to communicate our expectations with regard to our compliance programme. We encourage fairness, transparency, accountability and responsibility and recognise the need to prevent and detect illegal, improper and unethical conduct by Reed & Mackay, its directors or employees; and to demonstrate to stakeholders (including staff, customers and suppliers) how we are conducting our business.
To assist with our efforts, our expectation is that all our suppliers, agents, advisers and other third parties performing services for Reed & Mackay share our commitment to ensuring that the high standards of business integrity are maintained. We therefore ask that you comply with the Supplier Operating Principles in this document. We may update these principles at any time.
Continuing to work with Reed & Mackay, is taken as acceptance of these terms. Suppliers should promptly inform their Reed & Mackay contact if they are unable to comply with these operating principles, or if this
becomes likely.
Reed & Mackay reserves the right to audit or otherwise review suppliers’ compliance with these operating principles, its contract or any other agreements with Reed & Mackay, and may use independent third parties to assist with these activities. Reed & Mackay expects any findings highlighted as a result of such audits or reviews to be remediated and will assist with such remediation where appropriate.
EXPECTATIONS ON REED & MACKAY SUPPLIERS
- Suppliers are expected to have management systems in place for delivering compliance with the Operating Principles set out in detail within this document, both within their own operations and those of their suppliers.
- Suppliers must comply with all relevant legislation in the countries in which they operate and all relevant International Labour Organisation (ILO) conventions.
- Suppliers are expected to communicate their expectations for compliance with all aspects of the Operating Principles to all relevant employees, contractors and suppliers.
- Suppliers should be able to provide evidence to enable assessment of the implementation of the
Operating Principles by Reed & Mackay, those acting on our behalf and other relevant independent 3rd parties, if requested. - Suppliers should demonstrate continuous improvement in their approach to sustainable and responsible purchasing.
ANTI-BRIBERY & ANTI-CORRUPTION
Reed & Mackay values its reputation for ethical behaviour and financial probity; is committed to the highest legal and ethical standards; and has adopted a zero-tolerance approach to bribery.
It is a mandatory requirement that all suppliers, agents, advisers and other third parties performing services for Reed & Mackay also comply with our approach and have appropriate anti-bribery policies and procedures in place and comply any anti-bribery & anti-corruption laws applicable to their business. If no such anti-bribery or corruption laws apply or are of a lesser standard than that prescribed in the UK Bribery Act, suppliers, representatives and their employees must adhere to the UK Bribery Act. Failure to have adequate procedures in place to prevent bribery occurring may result in immediate termination of your contract or other arrangements with us and our clients. In addition, it may also result in criminal liability.
Our expectation is that all our suppliers, agents, advisers and other third parties performing services for Reed &
Mackay share Reed & Mackay’s commitment to ensuring that the high standards of business integrity are maintained. We therefore ask that you promptly report to our Global Finance Director, via your Reed & Mackay contact, any request for, or payment of any inappropriate financial or other advantage of any kind that you may receive, or are offered, in connection with your arrangements with Reed & Mackay and its clients. You must not offer or give any inappropriate financial or other advantage in connection with your arrangements with Reed & Mackay and its clients.
Our commitment to conducting our business with the highest degree of integrity includes Reed & Mackay adhering to a gift and hospitality policy, which covers gifts and hospitality from our suppliers, agents, advisers and other third parties performing services for Reed & Mackay. It may therefore happen that from time to time your hospitality is politely refused, and we hope that you understand the reasons for that.
ANTI-MONEY LAUNDERING
Reed & Mackay is committed to exercising due care and diligence to ensure that it conducts its business only with reputable clients and suppliers involved in lawful activities undertaken in good faith, and to operate an effective Anti-Money Laundering (AML) regime throughout the Company’s activities.
Reed & Mackay adheres to all current money laundering and terrorist financing prevention laws and regulations and compliance is compulsory as any breach may result in a criminal offence punishable by law. In addition, Reed & Mackay has an Anti-Money Laundering policy in place and has put in place other anti-money laundering measures and procedures covering all its offices. Reed & Mackay may carry our due diligence on suppliers including establishing the identity of key individuals, the partners, directors and any shadow directors and the identity of the business entity and its business activity.
It is a mandatory requirement that all suppliers, agents, advisers and other third parties performing services for Reed & Mackay also comply with anti-money laundering laws and regulations applicable to their business and have appropriate policies and procedures in place. Breaches of compliance and/or failure to have adequate procedures in place to prevent money laundering occurring may result in immediate termination of your contract or other arrangements with us and our clients. Our expectation is that all our suppliers, agents, advisers and other third parties performing services for Reed & Mackay share Reed & Mackay’s commitment to ensuring that the high standards of business integrity are maintained. We therefore ask that you promptly report to our Global Finance Director, via your Reed & Mackay contact, any suspicious activities that you may receive or are offered in connection with your arrangements with Reed & Mackay and its clients.
MODERN SLAVERY
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Reed & Mackay has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships, and ensuring modern slavery is not taking place anywhere in its business or supply chains. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under Modern Slavery legislation. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect that our suppliers will hold their own suppliers to the same high standards.
Reed & Mackay seeks to ensure that the working conditions of our suppliers meet the standards of the International Labour Organisation (ILO) and the Universal Declaration of Human Rights (UDHR). It is understood that organisations must comply with national and other applicable laws and regulations and where there is conflict between these and this policy then the highest standards linked with such laws and regulations shall be applied. Where there is no conflict, we would expect that the provisions that give the greatest protection to workers should be applied.
We expect our suppliers to adopt and demonstrate the following standards of social compliance:
FORCED OR COMPULSORY LABOUR
There shall be no form of forced labour, including bonded labour, indentured labour, slave labour, or human trafficking.
Workers shall not be required to lodge “deposits” or their identity papers with their employer and are free to leave work when their shift ends and leave their employer after reasonable notice.
CHILD LABOUR
There shall be no recruitment of child labour (i.e., anyone below the legal minimum age in the countries of operation).
Companies should refrain from hiring workers under the age of 18 years old for positions where it could jeopardise health, safety or morals.
Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child.
These policies and procedures shall conform to the provisions of the relevant ILO standards.
FREEDOM OF ASSOCIATION & EMPLOYEE REPRESENTATION
Companies shall respect employees’ rights to form, join or not join a labour union or other organisation of their choice, and to bargain collectively in support of their mutual interests without prior authorisation and without fear of punitive actions such as intimidation, harassment or termination of employment.
Where the right to freedom of association and collective bargaining is restricted under law, the company shall facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.
The company shall take proactive measures to seek the views of employees about the company, respect employees’ rights to belong to trade unions and fully comply with our obligation to inform and consult employees.
NON-DISCRIMINATION & HARASSMENT
The company shall not accept any form of discrimination on the basis of age, disability, race, religion or belief, sex, sexual orientation, marriage or civil partnership, gender reassignment, pregnancy or maternity, ethnic and national origin, educational background, or socio-economic status within their business.
Employment-related decisions, from hiring to termination, must be based on relevant and objective criteria.
The company shall protect workers from any acts of physical, verbal, sexual or psychological harassment, abuse or threats in the workplace by either their fellow workers or their managers.
WORKING HOURS, WAGES & LEAVE
Workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment.
All disciplinary measures should be recorded.
WORKING HOURS
Working hours should not be excessive and employees shall be entitled to reasonable breaks while working and sufficient rest periods between shifts. Companies shall comply with the applicable laws relating to minimum wages, working hours, overtime and benefits. Wages must be paid in legal tender on a regular basis. Overtime must be on a voluntary basis.
Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions from wages not provided for by national law, without the express permission of the worker concerned.
Companies shall grant all employees the right to sick leave, annual holiday and parental leave in line with applicable laws.
EMPLOYMENT TERMS
All workers should be provided with simple, legally binding, written contracts which must detail the terms and conditions of their employment. Contracts should be clearly understandable to each worker.
Work performed should be on the basis of recognised employment law and practice. The company shall not employ part-time, short-term or casual labourers, trainees or “false” apprentices purely as a means of paying lower wages or offering fewer benefits.
Disciplinary and grievance procedures shall be clearly documented and communicated to all employees. All disciplinary measures of a serious nature shall be recorded.
HEALTH, SAFETY & HYGIENE
A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage, shall be provided.
Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
RESOURCES, SKILLS AND COMPETENCE
It is a given that suppliers to Reed & Mackay must have appropriate tools/technologies and skilled and competent resources in place, sufficient that products / services delivered to Reed & Mackay meet contractual requirements and our expectations. It is therefore required that all suppliers have robust processes in place to ensure that appropriate tools/technologies and resources are available. These processes should include, but not be limited to:
- Budgeting, planning or other mechanisms to allow current and future tools/technology and resource requirements to be met
- Robust processes to source, choose, implement, and maintain tools and technologies, and decommissions them when no longer required
- formal staff on-boarding processes including appropriate checking of candidate new hires (background security checks when applicable)
- On-going competency management, succession planning and regular training including security awareness, data protection and other compliance training as applicable
- On-going staff review/appraisal
- Formal disciplinary processes
- Formal off-boarding processes including prompt removal of access rights
ENVIRONMENT
Reed & Mackay is certified to ISO 14001, the international standard for Environmental Management and seeks to ensure that appropriate attention is paid to environmental issues when Reed & Mackay purchase products and services. Whilst we do not require our suppliers to hold the ISO 14001 certification, we expect them to maintain a management system / set of policies and procedures that enables them to ensure continuous improvement in environmental performance. Therefore, suppliers should be able to demonstrate:
- Documented policies regarding environmental management
- The ability to monitor and review environmental performance
- The degree to which operations are covered by recognised environmental management systems or the organisations intentions towards such certification
- The awareness of potentials environmental risks inherent in their production, service or sourcing activities
- The implementation of mechanisms and processes in place to mitigate or minimise potential environmental risks
- The degree to which products and services have been designed with environmental considerations in mind
Suppliers should seek to:
- Minimise the use of energy, water and raw materials where practical.
- Maximise the use of recyclable and renewable materials including energy where possible.
- Make practical efforts to minimise waste and dispose of it in a safe, efficient, and environmentally responsible manner
- Avoid contamination of the local environment and ensure that emissions, air, noise and odour pollution is, as a minimum, within nationally defined limits.
COMMUNITY IMPACT
Organisations are encouraged to support the communities in which they operate through appropriate initiatives including volunteering, fundraising, charitable donations etc. as appropriate.
USE OF REED & MACKAY LOGO & TRADEMARKS
Our image has an important role in portraying what Reed & Mackay stands for. We have developed a unique and distinctive crest and material that reflects the marketplace in which we do business. The Latin phrase with the mark, ‘SERVIENDO IACTATE’ means ‘Pride Through Service’. It has been designed to sit comfortably with the ‘professional’ audience, whilst also expressing our core values.
Under no circumstances should any part of the mark be recreated, without permission being granted in writing by our Marketing & Communications department. You should only use approved files, and it must be used in its entirety. Our Marketing & Communications department will be happy to provide approved files and assistance.
SOCIAL MEDIA
Reed & Mackay recognises the importance of participating in online social media in the right way and is committed to promoting best practice for those approved to engage on behalf of Reed & Mackay. Reed & Mackay does not condone manipulating social media by creating ‘fake’ posts designed to mislead followers and control a conversation. We are conscientious regarding any Personally Identifiable Information (PII) that we collect, including how we collect, store, use or share that information, all of which should be done in accordance to applicable Privacy Policies, laws and IT Policies.
Reed & Mackay ensures that respect of copyrights, trademarks, rights of publicity and other third-party rights in the online social media space, including with regard to user-generated content, is adhered to and we will not use or align with any organisation or websites that deploy the use of excessive tracking software, adware, malware or spyware.
There is a big difference in speaking ‘on behalf of the Company’ and speaking ‘about’ the Company. No suppliers should speak ‘on behalf of Reed & Mackay’; or contribute to or start any group or activity using Reed & Mackay’s name without prior written consent and guidance from the Marketing & Communications department. We request that suppliers refrain from making negative or disparaging comments about Reed & Mackay, but instead raise any issues or concerns with their Reed & Mackay contacts, so that they can be addressed satisfactorily.
CONFIDENTIALITY
There may be occasions in which we wish to disclose certain confidential information to each other. We will therefore require either a Confidentiality/Non-Disclosure clause within the contract or a Non-Disclosure Agreement between the parties to be in place. Any confidential, proprietary or trade secret information should be treated in accordance with such clauses/agreements.
INFORMATION SECURITY & DATA PROTECTION
Reed & Mackay is certified to ISO/IEC 27001, the international standard for Information Security Management. Whilst we do not require our suppliers to hold information security certifications, we expect them to maintain a management system / set of policies and procedures, along with the appropriate technical and organisational security measures that, in combination, enable them to maintain the highest standard of confidentiality, integrity and availability of information systems and data. Suppliers of products/services which interact with Reed & Mackay information systems or process personal data are required to meet our Supplier Information Security Requirements (available on request).
In addition, Reed & Mackay and its suppliers have a legal obligation to comply with data protection regulations. We expect our suppliers and their supply chain to adopt appropriate practises/methods in handling data in a secure manner in accordance with data protection regulations and any data protection clauses and/or agreements in place. These include:
- The pseudonymisation and encryption of personal data, as appropriate;
- The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing
systems and services; - The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
- A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing
We also expect suppliers to regularly review their information security and data protection measures to ensure there is no degradation in the level of information security and data protection provided, and improvements are made when appropriate. These reviews should, at a minimum, take into account changes in regulations, supply chain, technology, processes, data and threats.
Suppliers are required to notify Reed & Mackay of information security incidents or data breaches including, but not limited to, any incident or breach that –
- Results in actual loss or Reed & Mackay or its client’s data, or
- Affects the security of information assets or data handled for, or on behalf of Reed & Mackay
- Results in a financial, operational or reputational loss or regulatory action
Notifications should be made by e-mailing security.trust@reedmackay.com as soon as possible on becoming aware of such an incident/breach.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
Suppliers may only disclose information held about Reed & Mackay or its clients to other parties for the purpose of providing services requested (or where legitimately requested for legal or regulatory purposes, as part of legal proceedings or prospective legal proceedings). Prior permission must be obtained in writing and appropriate agreements put into place to ensure an adequate level of protection is given to such information.
DATA RETENTION & DISPOSAL
Reed & Mackay requires suppliers to retain information only for the purpose for which it was obtained, and for a period no longer than is necessary.
All suppliers have an obligation to dispose of personal, confidential and business critical information in a secure manner when requested by Reed & Mackay, upon termination of contract with Reed & Mackay or when no longer required.
This obligation applies to information in all its forms; stored on paper, electronically or held on film or other media. It includes text, pictures, audio and video and covers transmission by post, electronic means or oral communication, including telephone and voicemail. It applies throughout the lifecycle of the information from creation through storage/utilisation to disposal.
Hardware assets with the capability to store Reed & Mackay or its client’s data (e.g. PC, Server or SAN HDD/SDD), should be securely wiped to UK Communications Electronics Security Group (CESG) standards (or equivalent). If this secure data destruction is carried out by a third party (e.g. a waste disposal or recycling company) then a data destruction certificate must be provided by the third party.
All electronic assets must be disposed of in accordance with the European Waste Electrical and Electronic Equipment (WEEE) Directive (or equivalent).
In all instances full certification of recycling / destruction must be provided by the supplier of services and may be requested by Reed & Mackay.
PAYMENT CARD INDUSTRY–DATA SECURITY STANDARDS (PCI-DSS)
Reed & Mackay is PCI-DSS compliant and expects suppliers to exercise due diligence and take appropriate measures to protect and control the storage and transmission of credit card details in compliance with the Payment Card Industry’s Data Security Standard. Suppliers are responsible for the security of cardholder data they possess or otherwise store, process or transmit on behalf of Reed & Mackay, or to the extent that they could impact the security of the customer’s cardholder data environment.
LICENCES
Reed & Mackay require all suppliers to meet, and maintain throughout the life of the relationship, all the legal and regulatory licensing requirements applicable to the products/services provided to Reed & Mackay.
INSURANCE
Within the UK, it is a legal requirement that employers’ liability insurance in place to cover employees’ illness, bodily injury or disease caused during or arising from their employment.
Reed & Mackay expect all suppliers to have employers’ liability (or equivalent) insurance in place appropriate to their business and in accordance with national and other applicable laws and regulations. Where there is conflict between these laws and regulations and this policy then the highest standards linked with such laws and regulations shall be applied. Where there is no conflict, we would expect that the provisions that give the greatest protection to workers should be applied.
Beyond the legal requirement, Reed & Mackay also holds insurances appropriate to its business including, but not limited to, public liability insurance, professional indemnity insurance and cyber insurance. We expect all suppliers to have in place insurance covering similar risks as appropriate to their business and in accordance with national and other applicable laws and regulations.
All insurances should be regularly reviewed to ensure that the scope and level of cover remains appropriate.
BUSINESS CONTINUITY
Reed & Mackay is certified to ISO 22301, the international standard for Business Continuity Management. Whilst we do not require our suppliers to hold the ISO 22301 certification, we expect them to a maintain a management system / set of policies and procedures that enables them to provide a continuity of service in line with its contractual obligations, and to manage a crisis or business interruption in an effective, efficient and timely manner; minimising the impact on service to Reed & Mackay. We will work with the suppliers deemed as critical to our business to ensure they are fully aware of our policy and request them to adopt similar practices which work within agreed Recovery Time Objectives (RTOs), Recovery Point Objectives (RPOs) and Maximum Tolerable Periods of Disruption (MTPDs).
QUALITY ASSURANCE
Reed & Mackay has built a reputation for consistently delivering exceptional service through attention to the smallest details; ensuring that nothing is left to chance so that service is consistently delivered both effectively and efficiently. We are committed to understanding client requirements; making every effort to ensure their expectations are met or exceeded. We strive for continual improvement of both our processes and the service we provide. Reed & Mackay is certified to ISO 9001, the international standard for Quality Management. Whilst we do not require our suppliers to hold the ISO 9001 certification, we expect them to maintain a management system / set of policies and procedures that ensures that products/services delivered to Reed & Mackay meet expectations; enables suppliers to mirror Reed & Mackay’s passion for quality, extraordinary service and continual improvement; and to identify and address any risks to the provision of quality services to Reed & Mackay.
CONFLICTS OF INTEREST
A Conflict of Interest is a situation where what is in an individual’s best interest is not in the best interest of another individual or organization to which that individual owes loyalty.
For the purpose of these Principles, a potential conflict of interest occurs when the supplier’s (or supplier’s staff) interests interfere with Reed & Mackay’s interests.
It is the responsibility of suppliers to take active steps to disclose to Reed & Mackay, and manage any actual or potential conflicts of interest concerning your engagement with Reed & Mackay.
Examples of potential conflicts of interest are –
- a supplier has a material interest in Reed & Mackay or one of its subsidiaries, parent companies or direct competitors
- a family member of a Reed & Mackay employee is a director, sales representative or other employee of your company and will derive a direct benefit from the relationship with Reed & Mackay
UBOs AND POLITICALLY EXPOSED PERSONS
It is incumbent on suppliers to provide to Reed & Mackay, on request, details of their Ultimate Beneficial Owner(s) (UBOs) and inform Reed & Mackay if any of their UBOs or senior executives (directors/partners) could be considered to be “Politically Exposed Persons” (PEPs).
PEPs are individuals with “prominent public functions” (or who are family members, close business associates or beneficial owners of property of such individuals).
The following should be considered as prominent public functions –
- heads of state, heads of government, ministers, and deputy or assistant ministers
- members of Parliament
- members of courts of auditors or of the boards of central banks
- ambassadors, chargés d’affaires and high-ranking officers in the armed forces
- members of the administrative, management or supervisory bodies of state-owned enterprises
- members of supreme courts, constitutional courts or other high-level judicial bodies whose decisions are not generally subject to further appeal, except in exceptional circumstances
A UBO is the individual(s) who benefits the most and has ultimate control when an institution initiates a transaction, and can be defined as an individual who:
- holds, directly or indirectly, more than 25% of the shares in the company, or
- holds, directly or indirectly, more than 25% of the voting rights in the company, or
- holds the right, directly or indirectly, to appoint or remove a majority of the board of directors of the company, or
- has the right to exercise, or actually exercises, significant influence or control over the company.
SANCTIONED COUNTRIES, ENTITIES AND INDIVIDUALS
International sanctions are political and economic decisions against states, organisations or individuals to protect national security or international law and defend against threats to international peace and security. These decisions principally include the temporary imposition on a target of economic, trade, diplomatic, cultural or other restrictions (sanctions measures) that are lifted when the concerns no longer apply, or when no new threats have arisen.
Reed & Mackay will carry out sanctions checks on suppliers where possible, however it is incumbent on suppliers to inform Reed & Mackay if –
- they have operations in any location “sanctioned” by the UK, US, EU, UN or the government of the
country in which they are Head Officed - they are, or become, an entity “sanctioned” by the UK, US, EU, UN or the government of any location in which they operate
- they are, or become, owned or operated by an individual “sanctioned” by the UK, US EU, UN or the government of any location in which they operate
The UK sanction lists can be found here – The UK Sanctions List – GOV.UK
The US sanctions lists can be found here – https://ofac.treasury.gov/
The EU sanctions lists can be found here – Sanctions (restrictive measures) – European Commission
The UN sanctions lists can be found here – United Nations Security Council Consolidated List | Security Council
ANTI-COMPETIVE ACTIVITY
Reed & Mackay avoids all types of anti-competitive activity, and will not engage with suppliers who:
- Make agreements with other organisations not to compete with each other (a “cartel”) such as price fixing; bid rigging; sharing of markets; customers or commercially sensitive information
- Make clients buy products they do not want; charge prices that do not cover our costs in order to drive out competitors; treat similar clients differently (e.g. by offering materially different prices or terms for the same services); or otherwise abuse a “dominant position”
- Buy or sell jointly with its competitors
- Agree with its competitors to reduce production/availability of its services to raise their market value
- Restrict how much other businesses can sell its products/services for (if ever applicable)
- Agree with its competitors not to sell to certain clients or deal with certain suppliers
- Have long-term exclusive contracts with any clients or suppliers
SUPPLY CHAIN MANAGEMENT
Reed & Mackay expects suppliers to ensure that their own supply chain complies with the laws of the country or countries in which they operate, and that similar principles to those above are applied to their supply chain. We also expect suppliers to carry out appropriate due diligence on their supply chain prior to engagement, agree appropriate contracts with their suppliers, and to carry out periodic reviews of their suppliers as appropriate. Due diligence and review should include, but not be limited to, the following areas as applicable to the engagement: Corporate Governance (including Anti-Bribery & Anti-Corruption; Anti-Money Laundering; and Human Rights/Modern Slavery); Information Security; Data Protection; Business Continuity; Environmental; Sustainability; Quality; Health & Safety.
DOCUMENT REVISION HISTORY
VERSION
DATE
AUTHOR(S)
REVISION NOTES
2.0
29/03/2023
Andrew Milne
- Update to Modern Slavery sub-sections to align with new R&M Human Rights Policy
- Sanctioned Countries, Entities and Individuals – addition of reference to EU and UN sanctions lists Information Security & Data Protection – reference to Supplier Information Security Requirements
- Supply Chain Management – examples of Corporate Governance due diligence
- Referenced UN Global Compact
- Minor clarifications/amendments to language in the following sections – Expectations on R&M Supplier; Anti-Bribery & Anti- Corruption; Anti-Money Laundering; Community Impact; UBOs and Politically Exposed Persons; Confidentiality
- Included Document History
2.1
28/03/2024
Marisa Churcher
- New brand template
- New security incident email address security.trust@reedmackay.com
